Revision to the 

New Hampshire 

State Implementation Plan 

Maintenance Plan for 

Former 1-Hour Ozone Nonattainment Areas 

in Cheshire, Hillsborough, Merrimack, Rockingham, 

and Strafford Counties 

March 2, 2012 

Air Resources Division 
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New Hampshire Ozone Maintenance SIP Page i 

TABLE OF CONTENTS 

1. INTRODUCTION..................................................................................................1

1.1 Background...................................................................................................1 

1.2 National Ozone Standards..................................................................................1 

1.3 Attainment Status............................................................................................2 

1.4 SIP Revisions................................................................................................6 

1.5 Maintenance Plan Components.............................................................................7 

2. ATTAINMENT INVENTORY AND MAINTENANCE DEMONSTRATION..........................8 

2.1 2002 Attainment Inventory.................................................................................8 

2.2 2012 and 2014 Projected Inventories.....................................................................9 

2.3 Maintenance Demonstration..............................................................................10 

3. AMBIENT AIR QUALITY MONITORING.................................................................13 

4. CONTINGENCY PLAN.........................................................................................14 

4.1 ICI Boilers (at Major Point Sources)....................................................................15 

4.2 Emulsified Asphalt Paving...............................................................................15 

4.3 Consumer Products.........................................................................................15 

4.4 Additional Controls on Boilers...........................................................................16 

4.5 Other Contingency Measures............................................................................17 

5. VERIFICATION OF CONTINUED ATTAINMENT......................................................18 

6. ADMINISTRATIVE DOCUMENTS..........................................................................18 

7. SUMMARY.......................................................................................................18 

LIST OF FIGURES 

Figure 1-1 New Hampshire 1-hour and 8-hour Nonattainment Areas.........................................5 

LIST OF TABLES 

Table 1-1 New Hampshire Designations/Classifications for 1-Hour Ozone Standard 

Revised as of July 1, 2002 (40 CFR 81.330) ..........................................................3 

Table 1-2 New Hampshire Designations/Classifications for the 1997 8-Hour Ozone Standard 

Effective June 15, 2004 (FR 69 23857) ................................................................4 

Table 1-3 1-Hour Ozone Nonattainment/Maintenance Areas Designated Unclassifiable/ 

Attainment for the 1997 8-Hour Standard as of June 15, 2004...................................7 

Table 2-1 2002 vs. 2012 and 2014 NOx and VOC Emissions for Cheshire, Hillsborough, 

Merrimack, Rockingham, and Strafford Counties................................................10 

Table 3-1 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design 

Values Based on Fourth-Highest Annual Maxima................................................12 

Table 4-1 Estimated Emission Reductions from Three BOTW Control Measures........................14 

Table 4-2 Potential Contingency Measures for Reducing Ozone Levels...................................16 

LIST OF ATTACHMENTS 

Attachment A 2002 Attainment Inventory and 2012 and 2014 Projected Inventories 

Attachment B Administrative Documents 
New Hampshire Ozone Maintenance SIP Page ii 

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New Hampshire Ozone Maintenance SIP Page 1 

1. INTRODUCTION 

This maintenance plan, presented as a revision to New Hampshire’s State Implementation Plan 

(SIP), addresses the anti-backsliding provisions of the Clean Air Act, Section 110(a)(1), with 

respect to the former 1-hour ozone standard after promulgation of the 1997 8-hour ozone standard. 

The maintenance plan (also known as “maintenance SIP”) applies to former 1-hour ozone 

nonattainment areas constituting all of Cheshire County and portions of Hillsborough, Merrimack, 

Rockingham, and Strafford Counties. 

1.1 Background 

Under Section 110(a)(1), states are required to implement, maintain, and enforce national primary 

ambient air quality standards: 

“Each State shall, after reasonable notice and public hearings, adopt and submit to the Administrator, within 3 years 

(or such shorter period as the Administrator may prescribe) after the promulgation of a national primary ambient air 

quality standard (or any revision thereof) under section 109 for any air pollutant, a plan which provides for 

implementation, maintenance, and enforcement of such primary standard in each air quality control region (or 

portion thereof) within such State...” 

States are expected to meet these requirements through individualized State Implementation Plans. 

SIPs are dynamic documents describing the state’s statutory and regulatory (i.e., enforceable) 

emission control measures that will be implemented to ensure compliance with the national 

standards. SIPs must be periodically reviewed and updated to meet administrative requirements, 

changing air quality conditions, changing emissions, and new or amended federal programs. 

1.2 National Ozone Standards 

Since the 1970s, EPA has established and periodically reviewed/revised the national ambient air 

quality standards (NAAQS) for ground-level ozone. The original 1-hour primary standard of 0.08 

parts per million (ppm) for photochemical oxidants, promulgated by EPA in 1971 (Federal 

Register, 36 FR 8186), was revised in 1979 to a 1-hour standard of 0.12 ppm for ozone (44 FR 

8202). In 1993, after a lengthy period of scientific review, litigation, and public input, EPA decided 

to retain the 0.12 ppm standard (58 FR 13008). (Note: The secondary ozone standard was set 

identical to the primary standard.) 

On July 18, 1997, EPA published a final rule for a new 8-hour ozone standard of 0.08 ppm to 

replace the 1-hour standard (62 FR 38855), effective on September 16, 1997. This change was 

based on further scientific study concluding that the 1-hour standard did not provide adequate health 

protection against extended periods of moderately elevated ozone levels. The 1997 8-hour ozone 

NAAQS bore a more direct relationship to ozone concentrations associated with health effects. 

As part of the transition to the more protective 8-hour standard, the agency issued rules determining 

that the 1-hour standard no longer applied in certain areas. EPA subsequently rescinded this action 

in response to litigation that created uncertainty as to when and whether the 8-hour standard would 

be fully implemented. A rule reinstating the 1-hour standard was published on July 20, 2000, and 

implementation of the newer standard was delayed for several years pending resolution of the legal 

issues. The Phase 1 implementation rule for the 8-hour ozone standard was published in final form 

on April 30, 2004 (69 FR 23857). On June 15, 2005, EPA revoked the 1-hour ozone standard for 

most areas of the country (including all of New Hampshire) and replaced it with the 8-hour ozone 

standard (69 FR 23857 and 70 FR 44470).
New Hampshire Ozone Maintenance SIP Page 2 

In 2008, EPA further strengthened the 8-hour NAAQS for ground-level ozone to 0.075 ppm, 

effective on May 27, 2008 (73 FR 16435). After reconsideration of the scientific evidence, on 

January 6, 2010, EPA proposed to reduce the standard to 0.060-0.070 ppm (75 FR 2938). In its 

final determination, however, headquarters clarified that “EPA fully intends to implement this 

current standard [0.075 ppm] as required under the Clean Air Act,” (memo from Gina McCarthy, 

Assistant Administrator, to the Regional Air Division Directors, September 22, 2011). While this 

provides historical context, the 2008 revision of the ozone NAAQS is irrelevant to the antibacksliding provisions that serve as the reason for this maintenance plan. This plan is therefore 

unaffected by EPA’s most recent actions to strengthen the 8-hour ozone standard.

1.3 Attainment Status 

 

The 1990 amendments to the Clean Air Act established an area classification system for attainment 

of the 1-hour ozone NAAQS. Under this system, all areas of the United States were designated as 

attainment, nonattainment, or unclassifiable, depending on the available monitoring data for those 

areas. In addition, attainment areas could be either classified or unclassifiable according to the 

adequacy of the monitoring data. 

Nonattainment areas were further classified as marginal, moderate, serious, severe, or extreme, to 

represent progressive levels of exceedance of the 1-hour ozone standard. The 1990 amendments 

also established mandatory SIP submission requirements based on the ozone nonattainment 

designation. 

New Hampshire’s area designations and classifications for the 1-hour ozone standard are codified at 

40 CFR 81.330 (Table 1-1). Counties in the northern and central parts of the state were designated 

as unclassifiable/attainment areas for 1-hour ozone. The more populous southeastern counties of 

Strafford, Rockingham, and Hillsborough, were designated as serious nonattainment areas. Southcentrally located Merrimack County was classified as a marginal nonattainment area. Cheshire 

County, in the state’s rural southwest corner, was designated as a nonattainment area on the basis of 

incomplete data. 

With the 1-hour area classifications already reinstated, on July 24, 2000, NHDES submitted to EPA 

its attainment classification recommendations for the newer, 8-hour standard. This submittal was 

followed by another, on July 15, 2003, that included consideration of Consolidated Metropolitan 

Statistical Area (CMSA) boundaries and other regional considerations in making recommendations 

for determining nonattainment areas for 8-hour ozone. 

Final attainment classifications for the 8-hour ozone standard appeared in the Federal Register on 

April 30, 2004 (69 FR 23857), with an effective date of June 15, 2004. EPA designated the New 

Hampshire portion of the Boston-Manchester-Portsmouth area as a moderate nonattainment area for 

the 8-hour ozone NAAQS (Table 1-2) with a maximum attainment date of June 15, 2010. It is 

worth noting that no monitor in New Hampshire had an 8-hour ozone design value equal to or 

greater than 0.092 ppm, a situation that normally would have put the nonattainment area in the 

marginal classification. However, NHDES agreed to the moderate classification to provide regional 

consistency with contiguous nonattainment areas extending from southern Maine to Massachusetts. 
New Hampshire Ozone Maintenance SIP Page 3 

 Table 1-1. New Hampshire Designations/Classifications for 1-Hour Ozone Standard 

Revised as of July 1, 2002 (40 CFR 81.330) 

Area County Cities and Towns Included Designation/ 

Classification 

Nonattainment Areas 

Merrimack (all) Allenstown, Andover, Boscawen, Bow, Bradford, 

Canterbury, Chichester, Concord, Danbury, 

Dunbarton, Epsom, Franklin, Henniker, Hill, 

Hooksett, Hopkinton, Loudon, New London, 

Newbury, Northfield, Tilton, Pembroke, Pittsfield, 

Salisbury, Sutton, Warner, Webster, Wilmot 

Nonattainment**/ 

Marginal** 

Hillsborough (part) Antrim, Bedford, Bennington, Deering, Francestown, 

Goffstown, Greenfield, Greenville, Hancock, 

Hillsborough, Lyndeborough, Manchester, Mason, 

New Boston, New Ipswich, Peterborough, Sharon, 

Temple, Weare, Windsor 

Nonattainment**/ 

Marginal** 

Manchester Area 

Rockingham (part) Auburn, Candia, Chester, Deerfield, Epping, Fremont, 

Northwood, Nottingham, Raymond 

Nonattainment**/ 

Marginal** 

Hillsborough (part) Pelham, Amherst, Brookline, Hollis, Hudson, 

Litchfield, Merrimack, Milford, Mont Vernon, 

Nashua, Wilton. 

Nonattainment*/ 

Serious** 

Boston-LawrenceWorcester Area 

Rockingham (part) Atkinson, Brentwood, Danville, Derry, East Kingston, 

Hampstead, Hampton Falls, Kensington, Kingston, 

Londonderry, Newton, Plaistow, Salem, Sandown, 

Seabrook, South Hampton, Windham 

Nonattainment**/ 

Serious** 

Rockingham (part) Exeter, Greenland, Hampton, New Castle, Newfields, 

Newington, Newmarket, North Hampton, Portsmouth, 

Rye, Stratham 

Nonattainment**/ 

Serious** 

Portsmouth-DoverRochester Area 

Strafford (all) Barrington, Dover, Durham, Farmington, Lee, 

Madbury, Middleton, Milton, New Durham, 

Rochester, Rollinsford, Somersworth, Strafford 

Nonattainment**/ 

Serious** 

Cheshire County Cheshire (all) Alstead, Chesterfield, Dublin, Fitzwilliam, Gilsum, 

Harrisville, Hinsdale, Jaffrey, Keene, Marlborough,

Marlow, Nelson, Richmond, Rindge, Roxbury, 

Stoddard, Sullivan, Surry, Swanzey, Troy, Walpole, 

Westmoreland , Winchester 

Nonattainment**/ 

Incomplete 

Data** 

Unclassifiable/Attainment Areas 

Belknap County Belknap all Unclassifiable/ 

Attainment 

Sullivan County Sullivan all Unclassifiable/ 

Attainment 

AQCR 107 Androscoggin 

Valley Interstate 

Coos all Unclassifiable/ 

Attainment 

Carroll all Unclassifiable/ 

Attainment 

AQCR 149 Central New 

Hampshire Interstate 

Grafton all Unclassifiable/ 

Attainment 

* October 18, 2000 ** January 16, 2001 
New Hampshire Ozone Maintenance SIP Page 4 

Table 1-2. New Hampshire Designations/Classifications for the 1997 8-Hour Ozone Standard 

Effective June 15, 2004 (FR 69 23857) 

Area County Cities and Towns Included Designation/ 

Classification 

Nonattainment Areas 

Hillsborough (part) Amherst, Bedford, Brookline, Goffstown, Hollis, Hudson, 

Litchfield, Manchester, Merrimack, Milford, Nashua, Pelham 

Nonattainment 

Subpart 2/Moderate

Merrimack (part) Hooksett Nonattainment 

Subpart 2/Moderate 

Rockingham (part) Atkinson, Auburn, Brentwood, Candia, Chester, Danville, 

Derry, E. Kingston, Epping, Exeter, Fremont, Greenland, 

Hampstead, Hampton, Hampton Falls, Kensington, 

Kingston, Londonderry, New Castle, Newfields, 

Newington, Newmarket, Newton, North Hampton, 

Plaistow, Portsmouth, Raymond, Rye, Salem, Sandown,

Seabrook, South Hampton, Stratham, Windham 

Nonattainment 

Subpart 2/Moderate 

Boston-ManchesterPortsmouth Area 

(Southeast New 

Hampshire Area) 

Strafford (part) Dover, Durham, Rochester, Rollinsford, and Somersworth Nonattainment 

Subpart 2/Moderate

Unclassifiable/Attainment Areas 

Hillsborough County Hillsborough (part) Antrim, Bennington, Deering, Francestown, Greenfield, 

Greenville, Hancock, Hillsborough, Lyndeborough, Mason, 

Mont Vernon, New Boston, New Ipswich, Peterborough,

Sharon, Temple, Weare, Wilton, Windsor 

Unclassifiable/ 

Attainment 

Merrimack County Merrimack (part) Allenstown, Andover, Boscawen, Bow, Bradford, 

Canterbury, Chichester, Concord, Danbury, Dunbarton, 

Epsom, Franklin, Henniker, Hill, Hopkinton, Loudon, 

New London, Newbury, Northfield, Pembroke, Pittsfield, 

Salisbury, Sutton, Warner, Webster, Wilmot 

Unclassifiable/ 

Attainment 

Rockingham County Rockingham (part) Deerfield, Northwood, Nottingham Unclassifiable/ 

Attainment 

Strafford County Strafford (part) Barrington, Farmington, Lee, Madbury, Middleton, Milton, 

New Durham, Strafford 

Unclassifiable/ 

Attainment 

Belknap County Belknap all Unclassifiable/ 

Attainment 

Carroll County Carroll all Unclassifiable/ 

Attainment 

Cheshire County Cheshire all Unclassifiable/ 

Attainment 

Coos County Coos all Unclassifiable/ 

Attainment 

Grafton County Grafton all Unclassifiable/ 

Attainment 

Sullivan County Sullivan all Unclassifiable/ 

Attainment 

The nonattainment areas listed above for the 1-hour and 8-hour ozone standards are represented 

graphically in the map of Figure 1-1. 

Note that these area classifications applied at specific dates during the first half of the previous 

decade. Because of regional progress in reducing emissions, some locations formerly identified as 

nonattainment areas have since achieved attainment. Also, because of recent improvements in 

monitoring, some locations formerly designated as unclassified attainment areas could now be 

redesignated as classified attainment areas. The classifications as listed here are relevant to this 

maintenance SIP. 
New Hampshire Ozone Maintenance SIP Page 5 

Figure 1-1. New Hampshire 1-hour and 8-hour Nonattainment Areas 
New Hampshire Ozone Maintenance SIP Page 6 

1.4 SIP Revisions 

On June 30, 1998, NHDES submitted to EPA an ozone attainment demonstration for the New 

Hampshire portion of the Boston-Lawrence-Worcester 1-hour ozone serious nonattainment area. 

As required under the Clean Air Act, this SIP revision was a plan for achieving attainment of the 1-

hour ozone standard in the affected area. The final rule approving the attainment demonstration SIP 

was published on December 6, 2002 (67 FR 72574), and became effective on January 6, 2003. The 

final rule set an attainment date of November 15, 2007, and also approved the attainment-level 

vehicle emissions budgets for NOx and VOC for the New Hampshire portion of the BostonLawrence-Worcester serious nonattainment area for use in meeting transportation conformity. 

On December 30, 2004, NHDES submitted the required mid-course review for the New Hampshire 

portion of the Boston-Lawrence-Worcester 1-hour ozone serious nonattainment area. EPA gave 

notice, on October 12, 2005 (70 FR 59338), that New Hampshire had submitted an acceptable midcourse review and fulfilled its commitment made in the attainment demonstration plan. 

On December 14, 2011, EPA published a proposed rule (76 FR 77739) determining that the BostonLawrence-Worcester MA-NH serious one-hour ozone nonattainment area met the November 15, 

2007, deadline for attaining the one-hour NAAQS for ozone, based on quality-assured, certified data 

for the 2005-2007 monitoring period. 

When the attainment classifications for the 1997 8-hour ozone standard were issued in mid-2004, 

some locations in New Hampshire that were previously found to be in nonattainment for the 1-hour 

ozone standard were determined to be in attainment for the 8-hour ozone standard. Although the 8-

hour standard superseded the 1-hour standard, anti-backsliding provisions established at 40 CFR 

51.905 required states to develop maintenance plans to prevent degradation of air quality in former 

nonattainment areas that were reclassified to attainment. In this instance, a maintenance plan was 

required for: 

• Any attainment area or unclassifiable area for the 8-hour ozone standard that was formerly 

in nonattainment for the 1-hour ozone standard, or 

• Any attainment area or unclassifiable area for the 8-hour ozone standard that was formerly 

in nonattainment for the 1-hour ozone standard but that achieved attainment with an 

approved maintenance plan. 

Table 1-3 lists the specific locations in New Hampshire that meet these qualifications and are covered

by this maintenance SIP. They include all, or portions of, the following five southern New 

Hampshire counties: Cheshire, Hillsborough, Merrimack, Rockingham, and Strafford (see the 

green-shaded area in the map of Figure 1-1). 
New Hampshire Ozone Maintenance SIP Page 7 

Table 1-3. 1-Hour Ozone Nonattainment/Maintenance Areas Designated 

Unclassifiable/Attainment for the 1997 8-Hour Standard as of June 15, 2004 

(= Maintenance Planning Area)1

Area County Cities and Towns Included

Boston-LawrenceWorcester Area Hillsborough (part) Mont Vernon, Wilton 

Hillsborough (part) Antrim, Bennington, Deering, Francestown, Greenfield, Greenville, 

Hancock, Hillsborough, Lyndeborough, Mason, New Boston, 

New Ipswich, Peterborough, Sharon, Temple, Weare, Windsor 

Manchester Area 

Merrimack (part) Allenstown, Andover, Boscawen, Bow, Bradford, Canterbury, 

Chichester, Concord, Danbury, Dunbarton, Epsom, Franklin, Henniker, 

Hill, Hopkinton, Loudon, New London, Newbury, Northfield, 

Pembroke, Pittsfield, Salisbury, Sutton, Warner, Webster, Wilmot 

Rockingham County Rockingham (part) Deerfield, Northwood, Nottingham 

Strafford County Strafford (part) Barrington, Farmington, Lee, Madbury, Middleton, Milton, 

New Durham, Strafford 

Cheshire County Cheshire (all) Alstead, Chesterfield, Dublin, Fitzwilliam, Gilsum, Harrisville, 

Hinsdale, Jaffrey, Keene, Marlborough, Marlow, Nelson, Richmond, 

Rindge, Roxbury, Stoddard, Sullivan, Surry, Swanzey, Troy, Walpole, 

Westmoreland , Winchester 

1.5 Maintenance Plan Components 

The maintenance plan must be in the form of a SIP revision providing for continued maintenance of 

the 8-hour ozone NAAQS in the planning area for 10 years from the effective date of the area’s 

designation as unclassifiable/attainment. The maintenance plan must contain, at a minimum, the 

following elements: 

• an attainment inventory, 

• a maintenance demonstration, 

• provisions for continued ambient air quality monitoring, 

• a contingency plan, and 

• verification of continued attainment. 

The required plan elements are addressed in the sections which follow. 

 

1

 Source: Table 2 of EPA’s “Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas under Section 

110(a)(1) of the Clean Air Act,” May 20, 2005. 
New Hampshire Ozone Maintenance SIP Page 8 

2. ATTAINMENT INVENTORY AND MAINTENANCE DEMONSTRATION 

The maintenance plan must demonstrate that the planning area will remain in compliance with the 

8-hour ozone standard for the 10-year period following the effective date of designation as 

unclassifiable/attainment. To make this demonstration, a state may use either an emissions 

inventory approach or other methods such as modeling. New Hampshire is using the emissions 

inventory approach to demonstrate that future emissions of ozone precursors (NOx and VOC) will 

not exceed attainment inventory levels. Thus, the analysis requires development of a baseline 

attainment inventory as well as an inventory of future emissions for the projection year, at a 

minimum. For areas (including New Hampshire) with an effective attainment designation date of 

June 15, 2004, for the 1997 8-hour ozone standard, the maintenance plan must project attainment for 

2014. In addition, an emissions inventory was developed for an interim year (2012) to demonstrate 

that maintenance of the ozone standard is likely to continue throughout the 10-year period. 

New Hampshire’s 2002 attainment inventory and projected 2012 and 2014 inventories presented in 

this section are divided into the following general emissions categories: 

• Point Sources, which represent discrete facilities. These sources must usually meet certain 

emission thresholds to be included as point sources and therefore generally represent larger 

facilities. 

• Area Sources, which represent facilities and activities too numerous and widespread to be 

inventoried individually but which collectively may account for significant emissions. 

• Non-Road Mobile Sources, including aircraft, locomotives, commercial marine vessels, 

construction vehicles, lawn & garden equipment, and other mobile vehicles and equipment 

that are not meant to be operated on roadways. 

• On-Road Mobile Sources, including cars, trucks, buses, motorcycles, and other vehicles that 

operate on public roadways. 

To complete the inventories, NHDES followed EPA guidance for making emission estimates of 

NOx and VOC on a typical summer day. The inventories were prepared for the five southern New 

Hampshire counties of Cheshire, Hillsborough, Merrimack, Rockingham and Strafford. Note, 

however, that the maintenance planning area includes only parts of Hillsborough, Merrimack, 

Rockingham and Strafford Counties. It is sometimes difficult or impractical to apportion emissions 

to a resolution finer than the county level; and the irregular geography of the maintenance planning 

area presented a particular challenge in this regard. However, because the maintenance planning 

area constitutes a large geographic portion of the entire 5-county area, NHDES reasoned that 

emission trends in the five southern counties would serve as an acceptable proxy for emissions 

trends in the maintenance planning area; the additional effort required to extract the estimates 

specific to the planning area would add little value to the analysis. Therefore, to the extent that the 

inventory data show declining emissions in the 5-county area as a whole, the data also reflect 

improving air quality within the maintenance planning area. 

2.1 2002 Attainment Inventory

The maintenance plan starts with a baseline attainment inventory of emissions, which details the 

volatile organic compounds (VOC) and oxide of nitrogen (NOx) emissions for the planning area on 

a “typical summer day.” The Phase 1 implementation rule for the 8-hour ozone standard specifies 

that the 10-year maintenance period begins on the effective date of the 8-hour ozone NAAQS 
New Hampshire Ozone Maintenance SIP Page 9 

designation. Although a state may use any of the three years upon which the 8-hour ozone 

designation was based (i.e., 2001, 2002 and 2003), EPA recommends that areas use 2002 as the 

attainment inventory base year.2

NHDES previously prepared a 2002 Periodic Emissions Inventory for ozone precursors to satisfy 

New Hampshire’s obligations under the Consolidated Emissions Reporting Rule (CERR). NHDES 

formally submitted its 2002 Periodic Emissions Inventory to EPA on June 7, 2007 (cover letter to 

Robert Varney). For the purposes of this maintenance plan, New Hampshire is using that inventory 

as a basis for its 2002 attainment inventory for all source categories. 

Affected point-source facilities in New Hampshire are required to report their emissions on an 

annual basis. The reporting requirements are specified under New Hampshire’s air regulations, air 

permitting program, and the CERR. The data submitted by these point-source facilities are 

extensively cross-checked and quality assured by NHDES staff before eventual submittal to EPA. 

Further details regarding New Hampshire point source data collection and quality assurance 

programs are available in Section A, “Point Sources,” of the documentation for New Hampshire’s 

2002 Periodic Emissions Inventory. 

The methodologies that New Hampshire used to prepare its 2002 periodic area source emissions 

inventory came primarily from EPA’s Emissions Inventory Improvement Program (EIIP). 

Methodologies for specific area source categories can be found in EIIP Volume 3, Area Sources, 

available at http://www.epa.gov/ttn/chief/eiip/techreport/volume03/index.html. Calculations for 

many area source categories are based on variables such as population, employment, and fuel 

consumption data. Detailed descriptions of the methodologies used in the 2002 area source 

inventory can be found in Section B, “Area Source Emissions,” of the documentation for New 

Hampshire’s 2002 Periodic Emissions Inventory. 

For the non-road mobile category, New Hampshire used the appropriate models for estimating nonroad vehicle emissions, including the Federal Aviation Agency’s (FAA’s) Emissions & Dispersion 

Modeling System (EDMS) for aircraft and airport ground service equipment and EPA’s 

NONROAD model for other non-road equipment types. New Hampshire also used applicable 

references and methodologies for estimating emissions for those equipment types not included in 

the EDMS and NONROAD models such as locomotives and CMVs. Detailed descriptions of the 

methodologies used by New Hampshire in its 2002 non-road mobile inventory can be found in the 

non-highway mobile sources portion of Section B, “Area Source Emissions” of the documentation 

for New Hampshire’s 2002 Periodic Emissions Inventory. 

For on-road mobile sources, New Hampshire used vehicle-miles-traveled (VMT) data obtained 

from the New Hampshire Department of Transportation and EPA’s MOVES motor vehicle 

emission factors model. 

2.2 2012 and 2014 Projected Inventories 

In accordance with EPA guidance, NHDES prepared an estimate of ozone-precursor emissions 

projected to 10 years after June 15, 2004, the effective date of the 8-hour ozone attainment 

designation. NHDES also prepared emission estimates for the interim year 2012. For both 

projected inventories, NHDES used the Economic Growth and Analysis System (EGAS) Version 

 

2

 EPA’s Consolidated Emissions Reporting Rule (CERR) already requires the development of a 2002 inventory (40 

CFR Part 51, Subpart A, 67 FR 39602, June 10, 2002). 
New Hampshire Ozone Maintenance SIP Page 10 

5.0 to develop the applicable growth factors (except for NONROAD model sources and on-road 

mobile sources, as noted below). These growth factors were matched to the appropriate point, area, 

and mobile source categories using Source Classification Codes (SCC). 

With respect to area sources, New Hampshire has adopted or is evaluating various control measures 

for a number of VOC source categories such as solvent cleaning, architectural surface coating, etc. 

For those measures that are not yet SIP-approved, the attendant emission reductions benefits are 

omitted from the 2012 and 2014 inventories. As a consequence of this conservative approach, it is 

anticipated that the actual projected emissions in those years will be lower than the projected 

emissions presented herein. 

Because analysis year is an inherent input into the NONROAD model, projected 2012 and 2014 

non-road mobile emissions were estimated directly for those non-road equipment categories that are 

included in the model. For other non-road mobile categories such as aircraft, locomotives, and 

CMVs, the appropriate EGAS growth factors were used. For commercial aircraft and airport 

ground service equipment, the EGAS growth factors were applied to the specific activities (e.g., 

aircraft landing-takeoff operations); and the growth-adjusted values were then input into the EDMS 

model. (Note: The EDMS model uses the analysis year to select the appropriate emission factors.) 

For on-road mobile sources, future-year VMT data was derived using trends in historical VMT from 

the Federal Highway Administration (FHWA) and from the Metropolitan Planning Organizations 

(MPOs) that represent New Hampshire's ozone nonattainment area. The transportation demand 

models used by the MPOs utilize population, employment, and other economic factors to growthadjust future-year VMT. Vehicle population data was adjusted for subsequent years using the 

growth factors from Table 3-14 of MOVES2010 Highway Vehicle Population and Activity Data, 

EPA-420-R-10-026, November 2010. 

2.3 Maintenance Demonstration 

Table 2-1 summarizes the 2002 attainment inventory and the projected 2012 and 2014 inventories 

for the five southern New Hampshire counties that encompass the Section 110(a)(1) maintenance 

planning area. As the inventory data show, total emissions of NOx and VOC are anticipated to 

decrease significantly through the period ending in 2014. 

Table 2-1. 2002 vs. 2012 and 2014 NOx and VOC Emissions for Cheshire, Hillsborough, 

Merrimack, Rockingham, and Strafford Counties (pounds per day) 

NOx VOC Source Category 2002 2012 2014 2002 2012 2014 

Point 67,347 48,358 50,739 15,898 6,696 7,005 

Area 10,516 9,091 9,134 93,778 85,443 91,068 

Non-Road Mobile 49,787 36,131 31,215 68,223 40,210 35,121 

On-Road Mobile 261,303 75,202 62,347 87,161 36,904 34,245 

Total 388,953 168,782 153,435 265,060 169,253 167,439 

The figures shown above for the 2002 attainment inventory differ somewhat from those previously 

submitted for the 2002 Periodic Emissions Inventory. The reasons for these differences are as 

follows: 
New Hampshire Ozone Maintenance SIP Page 11 

• The on-road mobile emissions estimates for the maintenance plan were calculated with 

MOVES, which was not available at the time that the 2002 Periodic Emissions Inventory 

was prepared. On-road mobile emissions estimates for the 2002 Periodic Emissions 

Inventory were calculated using MOBILE6.2 emission factors. 

• Similarly, emissions estimates for Stage II vapor recovery vehicle refueling (SCC 25-01-

060-100) for the maintenance plan were calculated with MOVES and were included and 

reported in the on-road mobile category. Stage II emissions estimates for the 2002 Periodic 

Emissions Inventory were calculated using MOBILE6.2 emission factors and were reported 

in the area source category. Since this category is now calculated with MOVES and 

included under on-road mobile, the MOBILE6.2-based Stage II refueling emissions 

estimates were removed from the area source inventory. This resulted in an adjustment to 

the 2002 maintenance plan area source inventory of -2,638 pounds per day of VOC when 

compared with the previously submitted 2002 Periodic Emissions Inventory. 

• In compiling the 2002 figures for the maintenance plan, it was discovered that emissions 

estimates for the industrial wood combustion category (SCC 21-02-008-000) should not 

have been calculated and reported under the area source category. All industrial wood 

combustion in 2002 would have occurred at permitted point source facilities, and making an 

area source estimate for this category caused double-counting. Therefore, the area source 

estimate for industrial wood combustion was removed. This resulted in a correction to the 

2002 maintenance plan area source inventory of -25,357 and -880 pounds per day of NOx 

and VOC respectively when compared with the previously submitted 2002 Periodic 

Emissions Inventory. 

The projected reductions in 2012 and 2014 are due to the various federal and state programs to 

control emissions from non-road and on-road mobile sources and to the gradual replacement over 

time of older, more polluting vehicles with newer, cleaner ones. Contributing to projected emission 

reductions from the non-road mobile sector are the following federal programs: 

• “Control of Air Pollution; Determination of Significance for Nonroad Sources and 

Emissions Standards for New Nonroad Compression Ignition Engines at or above 37 

Kilowatts,” 59 FR 31306, June 17, 1994. 

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines,” 63 FR 56967, 

October 23, 1998. 

• “Control of Emissions from Nonroad Large Spark-Ignition Engines and Recreational 

Engines (Marine and Land-Based),” final rule, 67 FR 68241, November 8, 2002. 

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel.” final rule, 

April 2004. 

Also contributing to projected emission reductions are the following federal/state onroad mobile 

source control measures: 

• Reformulated gasoline in Hillsborough, Merrimack, Rockingham, and Strafford Counties; 

• An enhanced safety inspection program, including a vehicle anti-tampering inspection for 

vehicles less than 20 years old; 
New Hampshire Ozone Maintenance SIP Page 12 

• On-board diagnostics testing for 1996 and newer vehicles in lieu of the anti-tampering 

inspection; 

• Participation in the National Low Emission Vehicle (Northeast) program; 

• The Federal Tier II vehicle standards and reduced gasoline sulfur limits. 

Regarding stationary sources, it should be noted that two relatively large VOC-emitting sources 

(Batesville Manufacturing, Inc. and Venture Holdings) have closed since the time of the 2002 

inventory. However, because NHDES has retained the emission reduction credits from these facility 

closures for possible future use, these emissions have been retained in the 2012 and 2014 inventories.

The inventory data clearly demonstrate that total emissions of ozone precursors within the fivecounty region are projected to decline between 2002 and 2014, indicating continued attainment of 

the 1997 8-hour ozone standard in the maintenance planning area. All of the technical data files 

associated with the 2002 attainment inventory and the 2012 and 2014 projected inventories are 

enclosed on CD-ROM as Attachment A. 

Section 110 of the Clean Air Act requires individual states to prevent air pollution emissions that 

would cause nonattainment of the NAAQS in downwind states. As NHDES has previously 

observed, over 92 percent of air pollution is transported into the state from other areas during 

periods of poor air quality.3 Through active participation in the Ozone Transport Commission 

(OTC), the Northeast States for Coordinated Air Use Management (NESCAUM), and other 

regional organizations, NHDES has cooperated extensively with upwind states and EPA to reduce 

emissions and achieve attainment of the 8-hour ozone standard. While New Hampshire’s continued 

attainment of this standard will depend on the success of in-state control measures, future 

attainment will depend to an even greater degree on the efficacy of super-regional control measures 

that reduce ozone and ozone-precursor transport into New Hampshire. 

 

3

 New Hampshire Department of Environmental Services, “Air Pollution Transport and How It Affects New Hampshire,” 

May 2004. 
New Hampshire Ozone Maintenance SIP Page 13 

3. AMBIENT AIR QUALITY MONITORING 

The maintenance plan for the 1997 8-hour ozone standard must include provisions for the operation 

of an ambient air quality modeling network to verify continued maintenance of the 8-hour ozone 

standard in the planning area. NHDES has monitoring stations throughout the state that record 

criteria pollutant levels and other air quality data. Table 3-1 presents 8-hour ozone monitoring data

for the most recent three-year period from monitors in the five southernmost counties of Cheshire, 

Hillsborough, Merrimack, Rockingham, and Strafford. The 2010-2011 design values and 2012 

threshold values provide further indication that the maintenance area is likely to continue meeting 

the 1997 8-hour ozone standard for the duration of the planning period. Based on quality-assured 

data through for the 2011 ozone season, the most recent design values were in the low- to mid-60’s 

parts per billion (ppb) range for most sites, and none was higher than 70 ppb. 

 

Table 3-1. 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design 

Values Based on Fourth-Highest Annual Maxima (ppb) 

 

4

th Highest Value Design Value*

Most Recent Year at 

Monitor or above Threshold 

Location 

AQS 

Number 2008 2009 2010 2011 2010 2011 

2012 

Threshold 

Value** 1

st Highest 4th Highest 

Keene 330050007 68 62 64 62 64 62 129 None None 

Peterborough 330115001 76 72 77 62 75 70 116 None None 

Nashua 330111011 67 66 67 65 66 66 123 None None 

Manchester 330110020 64 60 63 *** 62 *** *** None None 

Concord 330131007 67 64 68 64 66 65 123 None None 

Portsmouth 330150014 69 70 66 64 68 66 125 1988 None 

Rye 330150016 75 68 66 66 69 66 123 1991 None 

* Example: The 2010 design value is the 3-year average of the annual fourth-highest 8-hour ozone concentration for the period 

2008-2010. 

** The 2012 threshold value is the fourth-highest monitored daily maximum 8-hour ozone value during the 2012 ozone season 

that would cause the 2012 design value to exceed the 1997 8-hour ozone NAAQS. 

*** No data; monitor was moved to Londonderry in 2011.

New Hampshire is committed to the continuing operation of an effective air quality monitoring 

network to verify the area's attainment status in accordance with 40 CFR Part 58, to the extent that 

federal funding assistance remains sufficient for this purpose. New Hampshire proposes no 

modifications to the existing monitoring network at this time. Any future proposal to modify the 

monitoring network will be accompanied by supporting technical and statistical analyses as 

necessary. Final monitoring network design shall be subject to the approval of the EPA Regional 

Administrator.
New Hampshire Ozone Maintenance SIP Page 14 

4. CONTINGENCY PLAN 

As established at 40 CFR 51.905(a)(3)(iii) and (4)(ii)), the maintenance plan must include 

contingency provisions to correct any NAAQS violation that occurs after redesignation of an area. 

EPA guidance4 on this subject calls for contingency measures in the SIP, along with a schedule and 

procedure for adoption and implementation, that can be implemented in a timely fashion once they 

are triggered. The schedule should be as expeditious as practicable, but no longer than 24 months. 

The state should also identify specific indicators, or triggers, for setting the contingency plan into

action. Possible triggers would be a monitored exceedance of the 8-hour ozone standard or an 

exceedance of a precursor emission level on which maintenance is based. 

Despite New Hampshire’s best efforts to maintain compliance with air quality standards, the 

possibility exists that ambient ozone concentrations might at some future date exceed the NAAQS. 

Therefore, in accordance with the requirements of Section 175A(d), New Hampshire has identified 

various contingency measures that could be taken following an ozone “trigger” event and is 

committed to pursuing the following protocol:

1. At the conclusion of each ozone season, NHDES will evaluate whether the 8-hour ozone 

design value for any ozone monitor in the planning area is above or below the 1997 8-hour 

ozone standard (the “trigger”). The design value, in the case of this standard, is defined as 

the average of the annual 4th highest daily maximum 8-hour average concentration for the 

preceding 3-year period. 

2. If the design value is above the standard for any ozone monitor, NHDES will investigate the 

cause and determine whether the exceedance is due to: 

a. an increase in emissions from local, in-state sources; 

b. an increase in emissions from upwind, out-of-state sources; or 

c. exceptional event as defined in 40 CFR 50.1. 

3. If an increase in in-state emissions is determined to be a contributing factor to the exceedance, 

NHDES will evaluate the projected in-state emissions for the next ozone season. If the 

projected in-state emissions are not expected to decrease enough in the next ozone season to 

mitigate the violation, New Hampshire will implement one or more of the contingency 

measures listed below or will substitute other VOC or NOx control measures as necessary to 

achieve additional in-state emission reductions. 

4. The contingency measures(s) will be selected by the Governor or the Governor’s designee 

within six months of the end of the ozone season for which contingency measures have been 

determined to be needed. New Hampshire will then initiate a course of action to implement 

enforceable control measure(s) to rectify the problem. New rulemaking can typically be 

adopted and implemented within a 12-month timeframe. NHDES will update the 

maintenance plan as necessary and develop and implement required regulations as soon as 

practicable within the guidelines established in the New Hampshire Administrative Procedures 

Act, but no later than 18 months after selection of the appropriate measure. 

New Hampshire is studying an array of possible contingency measures that would achieve further 

reductions in NOx and VOC emissions, including the following emission controls previously 

proposed by the Northeast states: 

 

4

 See reference in footnote 1. 
New Hampshire Ozone Maintenance SIP Page 15 

• NOx controls for industrial, commercial, and institutional (ICI) boilers;

• VOC controls for emulsified and cutback asphalt paving; and 

• VOC controls for consumer products. 

These contingency measures are among several OTC control measures5 exceeding current on-thebooks/on-the-way (OTB/OTW) emission controls and serving as a subset of potential additional 

controls measures called beyond-on-the-way (BOTW). Details on BOTW control measures may be 

found in MACTEC’s report “Development of Emission Projections for 2009, 2012 and 2018 for 

NonEGU Point, Area and Nonroad Source in the MANE-VU Region,” Final Report, February 

2007. Estimated emission reductions for New Hampshire from the three named control measures 

are given in Table 4-1. 

Table 4-1. Estimated Emission Reductions from Three BOTW Control Measures 

Control Measure Pollutant 2009 Estimated Emission 

Reductions (tons per day) 

ICI Boilers (OTC 2006 Model Rule) NOx 1.9 

Emulsified Asphalt Paving (OTC guidelines) VOC 4.4 

Consumer Products (OTC 2006 Model Rule) VOC 0.3 

Source: MACTEC, 2007 

These potential contingency measures are further described in subparts 4.1 through 4.3, below. 

4.1 ICI Boilers (at Major Point Sources) 

In 2006, the OTC commissioners recommended that the OTC member states pursue “as necessary 

and appropriate” state-specific rulemakings to establish required emission reduction percentages, 

emission rate performance standards, or control technologies to reduce emissions from industrial, 

commercial, and institutional boilers (OTC Resolution 06-02). The approximately 2-ton-per-day 

reduction in NOx emissions from ICI boilers reported in Table 4-1 was based on implementation of 

OTC’s recommended control levels on boilers of 25-250 MMBtu/hr heat input capacity at major 

point sources in New Hampshire. 

4.2 Emulsified Asphalt Paving 

NHDES is currently evaluating the proposed contingency measure for emulsified asphalt paving. 

OTC’s guideline would limit the VOC content of emulsified asphalt to 2 percent or less. The VOC 

content of emulsified asphalt in New Hampshire is assumed to be 2.5 percent at present. Thus, the 

estimated VOC emission reduction from this source category would be approximately 20 percent 

during the ozone season. 

4.3 Consumer Products 

The contingency measure for consumer products included in Table 4-1 would replace the OTC 

2001 VOC model rules with the OTC 2006 model rules, which provide amendments (adopted by 

 

5

 MACTEC Federal Programs, “Identification and Evaluation of Candidate Control Measures,” Final Technical Support 

Document, Ozone Transport Commission, February 28, 2007. 
New Hampshire Ozone Maintenance SIP Page 16 

the California Air Resources Board (CARB) in July 2005. The amendments revise the existing 

VOC limit for contact adhesives and create VOC limits for nine new source categories (adhesive 

removers, electrical cleaner, electronic cleaner, fabric refresher, footwear or leather care, graffiti

remover, hairstyling products, toilet care, and wood cleaner). Based on estimates developed by 

CARB for 2009, these amendments would reduce VOC emissions by about 2 percent. 

4.4 Additional Controls on Boilers 

New Hampshire and the other OTC states have continued to investigate the possibility of additional 

controls on ICI boilers and utility boilers as stationary sources with the highest potential for NOx 

emission reductions. The additional controls would cover a wider range of boilers and would be 

more stringent than those described in the MACTEC report for non-EGU point sources and area 

sources in New Hampshire. More specifically, recent OTC proposals being considered by NHDES 

would provide additional NOx controls on the following boiler categories: 

• Oil- and gas-fired boilers serving EGUs (OTC 2010 Model Rule): This proposed rule would 

impose the following NOx emission limitations on oil- and gas-fired utility boilers with a 

nameplate capacity of 25 MW or greater: for gas only, 0.08 lb/MMBtu; for oil or oil/gas, 

0.15 lb/MMBtu. 

• New small natural-gas-fired boilers and water heaters (OTC 2010 Model Rule): This 

proposed rule would establish NOx emission standards for various devices ranging in size 

from 75,000 to 5,000,000 Btu/hr. 

• ICI boilers: Stricter NOx emission standards would be extended to any ICI boiler above a 

certain size threshold, e.g., 25 MMBtu/hr. 

Since 2006, OTC and the Lake Michigan Air Directors Consortium (LADCO) have worked 

collaboratively to assess the technical and economic feasibility of enhanced emission controls on 

ICI boilers of all sizes.6

 A NESCAUM study7 from the same time period examined a variety of 

technologies available to reduce NOx emissions from ICI boilers with heat input ratings from as 

low as 10 MMBtu/hr to as high as 1,000 MMBtu/hr. It was determined that emission reductions of 

5 to 90 percent are achievable, depending on boiler size, fuel type, and chosen technology. 

Generally, the higher control efficiencies are applicable to larger ICI boilers, of which New 

Hampshire has relatively few. 

NHDES is gathering data on New Hampshire’s current stock of ICI boilers by size, fuel type, and 

existing control level. Preliminary data indicate that approximately 80 percent of ICI boilers in the

state have heat input ratings less than 25 MMBtu/hr and lack NOx controls. Another 13 percent 

have heat input ratings less than 50 MMBtu/hr and lack NOx controls. These units – most of them 

burning fuel oil – account for more than half of all NOx emissions from ICI boilers in the state. 

Boilers with heat input ratings above 100 MMBtu/hr, while far fewer in number, would generally 

have some existing level of NOx controls. Given all of these facts, NHDES anticipates that any 

reasonable control program for ICI boilers in New Hampshire would be capable of reducing overall 

NOx emissions from this sector by 25 percent or more.

 

6 OTC and LADCO, “Evaluation of Control Options for Industrial, Commercial and Institutional (ICI) Boilers,” 

Technical Support Document, Final, May 14, 2010. 

7

 NESCAUM, Applicability and Feasibility of NOx, SO2, and PM Emission Control Technologies for Industrial, 

Commercial, and Institutional (ICI) Boilers, November 2008. 
New Hampshire Ozone Maintenance SIP Page 17 

Ongoing state and regional initiatives to control boiler emissions are overlain by EPA’s proposed or 

final rules pertaining to National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

industrial, commercial, and institutional (ICI) boilers at major sources and area sources; NESHAP 

for coal- and oil-fired electrical generating units; and New Source Performance Standards (NSPS) 

for fossil-fuel-fired electric utility and ICI boilers. Under these rules, affected sources would be 

subject to mandatory new emission limits and/or periodic boiler tune-ups that would yield direct 

emission reductions or indirect co-benefits with respect to NOx and VOC control. 

4.5 Other Contingency Measures 

NHDES is evaluating other potential NOx and VOC control measures that could be applied, if 

necessary, to further reduce ozone levels in the maintenance area. These control measures are listed 

in Table 4-2 along with the previously mentioned contingency measures for boilers, asphalt paving, 

and consumer products. 

Table 4-2. Potential Contingency Measures for Reducing Ozone Levels

Control Measure Source Category 

NOx Control Measures 

Oil and Gas Boilers Serving EGUs (OTC 2010 Model Rule) Major Point 

New Small Natural-Gas-Fired Boilers and Water Heaters (OTC 2010 Model Rule) Area* 

ICI Boilers Area or Major Point 

Stationary Generators (OTC 2010 Model Rule) Area 

Motor Vehicle Anti-Idling (mandatory, not voluntary) Onroad Mobile 

California Low-Emission Vehicles (CALEV) Standards Onroad Mobile 

Low-Carbon Fuel Standard (regional) Onroad Mobile / Nonroad 

VOC Control Measures 

Large above-Ground Storage Tanks (OTC 2010 Model Rule) Major Point 

Emulsified and Cutback Asphalt Paving (OTC guidelines) Area 

Adhesives and Sealants Application (OTC 2006 Model Rule) Area 

Architectural and Industrial Maintenance Coatings (OTC 2009 Model Rule) Area 

Solvent Cleaning (OTC 2009 Model Rule) Area 

Consumer Products (OTC 2006 Model Rule) Area 

Consumer Products (OTC 2010 Model Rule) Area 

Motor Vehicle and Mobile Equipment Non-Assembly Line Coatings Operations 

(OTC 2009 Model Rule) Area 

Stage II Vapor Recovery** Area 

*Area sources include minor emission sources, typically large in number and widely distributed. 

** Stage II Vapor Recovery would serve as a contingency measure upon determination of widespread use of ORVR. 
New Hampshire Ozone Maintenance SIP Page 18 

5. VERIFICATION OF CONTINUED ATTAINMENT 

EPA guidance calls upon the state to show how it will track the progress of the maintenance plan, 

i.e., demonstrate that compliance with the 8-hour ozone standard is being maintained during the 10-

year planning period. Tracking is necessary because the emission projections that form the basis of 

the maintenance demonstration depend on assumptions of point and area source growth and 

implementation of specific emission control measures. One option for tracking maintenance is to 

make periodic updates to the emissions inventory projections. Such an update could be based, in 

part, on the annual update of EPA’s national emissions inventory (NEI) database and could indicate 

new source growth and other changes from the attainment inventory (such as changes in vehicle 

miles traveled or in traffic patterns). 

New Hampshire will track the maintenance of attainment by analyzing air quality trends at local 

monitors and annually updating the state’s emissions inventories. NHDES routinely reviews air 

quality monitoring data and keeps charts showing trends in air quality at individual monitor sites. 

As required by law, New Hampshire produces comprehensive emissions inventories on a three-year 

cycle. The latest one, the 2008 inventory, will be completed this year, to be followed by formal 

inventories for 2011 and 2014. For the off-years, New Hampshire revises the inventories annually 

using updated emissions data for the largest sources.

6. ADMINISTRATIVE DOCUMENTS 

In accordance with the requirements for SIP submissions established in 40 CFR 51.103, the following 

documentation is herewith provided as integral to this maintenance plan: 

• A formal letter of submittal from the Governor or his designee, requesting EPA approval of 

this SIP revision; 

• Evidence that the NHDES has the necessary legal authority under state law to adopt and 

implement the plan. 

• Evidence that public notice was given of the proposed change consistent with procedures 

approved by EPA, including the date of publication of such notice. 

• Certification that public hearing(s) were held in accordance with the information provided in 

the public notice and the state's laws and constitution, if applicable and consistent with the 

public hearing requirements in 40 CFR 51.102. 

• Compilation of public comments and the state's response thereto. 

Documentation of legal authority, public notice, certification of the public process, and public 

comments and responses are provided in Attachment B. 

7. SUMMARY 

The State of New Hampshire is committed to achieving and maintaining air quality standards for 

ground-level ozone and its chemical precursors. The entire maintenance planning area is currently 

in attainment of the 1997 8-hour ozone NAAQS of 0.08 parts per million and is projected to stay in 

attainment for the duration of the 10-year planning period that ends on June 15, 2014. 
New Hampshire Ozone Maintenance SIP Page 19 

With this SIP revision, New Hampshire has met all Section 110(a)(1) maintenance plan 

requirements. The maintenance plan provides for continued compliance with the 8-hour ozone 

NAAQS in all areas that were classified as nonattainment areas for the former 1-hour ozone 

standard, as evidenced by the following plan elements: 

1. Attainment Inventory. New Hampshire compiled and used a 2002 baseline inventory of 

NOx and VOC emissions in accordance with EPA’s Consolidated Emissions Reporting Rule. 

2. Maintenance Demonstration. New Hampshire prepared 2012 and 2014 projected inventories 

of NOx and VOC emissions for comparison with the 2002 baseline inventory. These 

inventories indicate a sustained downward trend in NOx and VOC emissions within the 

maintenance planning area, demonstrating that the 1997 8-hour ozone standard will be 

maintained through at least 2014. The downward trend in NOx and VOC emissions is 

reinforced by ozone monitoring data, which show a similar, steady downward trend. (Note: 

New Hampshire recently prepared a 2008 Periodic Emissions Inventory as required by the 

Clean Air Act. This inventory has been submitted electronically to EPA for inclusion in the 

2008 National Emissions Inventory. It is also being submitted to EPA for SIP approval 

along with New Hampshire's redesignation request for the 1997 8-hour ozone nonattainment 

area. The 2008 inventory, although not directly related to the maintenance plan, is 

consistent with the stated trend in NOx and VOC emissions.) 

3. Ambient Air Quality Monitoring. New Hampshire is committed to the continued operation 

of an effective air quality monitoring network to verify maintenance of the planning area’s 

attainment status. 

4. Contingency Plan. New Hampshire has developed a contingency plan to ensure that any 

violations of the 8-hour ozone NAAQS, should they occur, are addressed and promptly 

corrected. 

5. Verification of Continued Attainment. New Hampshire is committed to tracking the 

maintenance of attainment at least annually – a frequency that would enable the 

implementation of contingency measures within a short timeframe, should such measures 

become necessary. Verification will be based on analysis of air quality trends and changes 

in emissions inventories. 
New Hampshire Ozone Maintenance SIP Page 20 

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ATTACHMENT A 

2002 Attainment Inventory and 

2012 and 2014 Projected Inventories 

(Files available on accompanying CD.) 
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ATTACHMENT B 

Administrative Documents: 

 Evidence of Legal Authority 

 Certification of Public Process 

 Copy of Public Notice 

 Public Comments and State’s Response 
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STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES AIR RESOURCES 

DIVISION CONCORD, NEW HAMPSHIRE NOTICE OF PUBLIC COMMENT PERIOD AND PUBLIC 

HEARINGS In accordance with New Hampshire Administrative Rule Env-A 204.01(b) and Title 

40 of the Code of Federal Regulations (CFR) Section 51.102, notice is hereby given that the 

New Hampshire Department of Environmental Services, Air Resources Division (the 

Department) has prepared, and intends to submit to the U.S. Environmental Protection Agency 

(EPA) for approval, a request for redesignation of the Boston-Manchester-Portsmouth (SE), 

New Hampshire 8-hour ozone (1997 standard) nonattainment area, including a maintenance 

plan for that area, hereinafter referred to as "Request for Redesignation (including MP I)," 

pursuant to section 110(a) of the federal Clean Air Act. This request, if approved by EPA, will 

revise New Hampshire's State Implementation Plan (SIP). In addition, the Department has 

prepared and intends to submit to EPA for approval as a SIP revision a maintenance plan, 

hereinafter referred to as "MP II," for the area of the state that was formerly designated 

nonattainment for the 1-hour ozone standard, but which was classified as 

unclassifiable/attainment for the 8-hour ozone standard. The Boston-Manchester-Portsmouth 

(SE), New Hampshire 8-hour ozone (1997 standard) nonattainment area consists of 52 cities 

and towns in the southern and/or eastern parts of Hillsborough, Merrimack, Rockingham, and 

Strafford Counties. Ground-level ozone monitoring data for the most recent 3-year monitoring 

period of 2008-2010 show that air quality in the nonattainment area has met the 1997 

National Ambient Air Quality Standard for 8-hour ozone. For EPA to approve the Request for 

Redesignation, the Department must submit maintenance plan MP I as part of this request, 

detailing how the state will insure that the area will not fall back into nonattainment once it is 

redesignated as attainment. MP I must demonstrate that the area will remain in compliance for 

a period of 10 years from the date of redesignation. The former nonattainment area for the 1-

hour ozone standard that was classified as unclassifiable/attainment for the 8-hour ozone 

standard on June 15, 2004, consists of 79 cities and towns in Cheshire County and the 

northern and/or western parts of Hillsborough, Merrimack, Rockingham, and Strafford 

Counties. The maintenance plan for this area, MP II, must demonstrate that the area will 

remain in compliance with the 8-hour ozone standard for the 10-year period from June 15, 

2004 to June 15, 2014. The Department hereby solicits comments and has scheduled public 

hearings on the Request for Redesignation (including MP I) and MP II. A public hearing on the 

Request for Redesignation (including MP I) has been scheduled for 10:30 a.m., Tuesday, 

January 24, 2012, at the Department offices in Rooms 110 and 111 at 29 Hazen Drive, 

Concord, NH 03301. A public hearing on MP II has been scheduled to start at the conclusion of 

the first hearing. Comments may be presented orally and/or in writing at the public hearings. 

Written comments may also be submitted by postal delivery, email, or fax to Charles Martone, 

Air Resources Division, NH Department of Environmental Services, P.O. Box 95, Concord, NH 

03302-0095; email Charles.Martone@des.nh.gov; fax (603)271-1381. Please specify which 

plan each comment addresses. All written comments on the Request for Redesignation 

(including MP I) and all written comments on MP II must be received by 4:00 p.m. on Tuesday, 

January 24, 2012, to be entered into the record. The Request for Redesignation (including MP 

I) and MP II are available for public inspection at the Department's offices at 29 Hazen Drive, 

Concord, NH, during regular working hours from 8:00 a.m. to 4:00 p.m., Monday through 

Friday. The main text of both documents may be downloaded from the Department's website 

at http://des.nh.gov/. Questions regarding the Request for Redesignation (including MP I) and 

MP II may be directed to Charles Martone at (603) 271- 1089. Robert R. Scott Director, Air 

Resources Division NH Department of Environmental Services Dated: December 23, 2011 

Appeared in: The Union Leader on Friday, 12/23/2011 
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Page 1 of 5 

Responses to Comments on 

New Hampshire's Proposed Maintenance Plan for 

Former 1-Hour Ozone Nonattainment Areas in Cheshire, Hillsborough, 

Merrimack, Rockingham, and Strafford Counties 

On January 24, 2012, the New Hampshire Department of Environmental Services (NHDES) 

received comments from the U.S. Environmental Protection Agency (EPA) on New Hampshire’s 

proposed Section 110(a)(1) maintenance plan for former 1-hour ozone nonattainment areas in 

Cheshire, Hillsborough, Merrimack, Rockingham, and Strafford Counties. No other comments 

were received. The following are NHDES’s responses to EPA’s comments. Comments are written 

in regular font and responses are written in italics.

1. On page 6, the citation “(40 FR 72574)” should be “(67 FR 72574).” 

Response: The citation has been corrected.

2. On page 6, the citation “(40 FR 59338)” should be “(70 FR 59338).” 

Response: As above.

Ozone Data

3. On page 12, Table 3-1 should identify that the ozone concentrations are presented in units of 

parts per billion (ppb). 

Response: The requested clarification has been added. 

4. On page 12, in Table 3-1, the 2012 threshold values should be as follows: 

Keene 129 ppb 

Peterborough 116 ppb 

Nashua 123 ppb 

Concord 123 ppb 

Portsmouth 125 ppb 

Rye 123 ppb 

Therefore, NH DES should adjust the “most recent year at or above the threshold” column 

correspondingly. In addition, it should be noted that in the current version of the table, it appears

that 1-hour values, rather than 8-hour values, were used when determining the most recent year at or 

above the threshold. 

Response: The 2012 threshold values and the most recent years at or above threshold have been 

corrected in the table.
Page 2 of 5 

Motor Vehicle Emission Estimates

5. The CD files submitted to EPA for review only included the MOVES2010 input and output files 

associated with the redesignation request. The final submittal of the Section 110(a)(1) maintenance 

plan should also include the MOVES2010 files associated with this plan. 

Response: Preliminary MOVES input/output files for the maintenance plan were mailed on a CDROM to Ariel Garcia, EPA, as requested in a phone call to Felice Janelle, NHDES. A complete 

data CD-ROM, including MOVES input/output files and supporting files for the 2002, 2012, and 

2014 emissions inventories, is being provided in association with this Section 110(a)(1) 

maintenance plan submittal. 

2002 Inventory and Projections to 2012 and 2014

6. Page 11 of the proposed maintenance plan for attainment areas in the 5-county, former 1-hour 

ozone nonattainment areas indicates that, 

“There has been a decline in actual point source VOC emissions since 2002, which is 

partially attributable to the closure of two relatively large VOC-emitting sources (Batesville 

Manufacturing, Inc., and Venture Holdings). However, because NHDES has retained the 

emission reduction credits from these facility closures for possible future use, these emission 

reductions are not included in the 2012 and 2014 inventories.” 

EPA suggests that NH DES clarify that although these facilities have been closed, their emissions 

have been retained in the 2012 and 2014 inventories. 

Response: The emissions reductions from the closings of Batesville Manufacturing and Venture 

Holdings were retained in the 2012 and 2014 inventories. The relevant wording in Section 2.3 of 

the maintenance plan has been revised to clarify this fact. 

7. New Hampshire selected its 2002 emissions inventory to use as the base year inventory for the 

maintenance plan developed to support redesignation of former l -hour nonattainment areas in the 

state. The 2002 inventory was submitted to EPA on June 7, 2007. New Hampshire's final 

maintenance plan submittal for this area should include a reference to the 2002 inventory submittal, 

as EPA will need to approve the 2002 inventory into the SIP. 

Response: The second paragraph of Section 2.1 of the maintenance plan has been revised to 

provide specific reference to the 2002 emissions inventory previously submitted to EPA. 

8. It is evident that New Hampshire intends to use full county inventories for the maintenance plan 

for the 5 county former 1-hour nonattainment areas. This should be clearly stated in the final 

maintenance plan submittal, particularly since the maintenance plan developed for New 

Hampshire’s 8-hour nonattainment area was not prepared using full counties, but rather, is based on 

the town by town geography of that area. 

Response: Full county inventories were used as a reasonable proxy for the irregularly-shaped 

geographic region that comprises the planning area for the maintenance plan. Wording in Section 

2 of the maintenance plan has been edited to explain and clarify this fact. 
Page 3 of 5 

9. The inventory estimates contained in the 2002 inventory are summarized in several different 

geographic arrangements. The closest summary that corresponds to the 5-county area that is the 

subject of this maintenance plan is the summary for the “1-hour 4-county area”. The four counties 

included in this summation are Hillsborough, Merrimack, Rockingham, and Strafford. By adding in 

emissions for Cheshire County, the inventory for the 5-county area that is the subject of the onehour redesignation request can be obtained. Table 1 below illustrates this exercise for VOC 

emissions using the 2002 emissions inventory, and then compares that sum to the emission 

estimates shown within Table 2-1 of the state's proposed maintenance plan for this area. Table 2 

illustrates this comparison for NOx emissions. 

The reasons for the differences in the 5 county total emission estimates should be identified and 

corrected. 

Response: The reasons for the differences in the 5 county total emissions between the 2002 

inventory and the proposed maintenance plan are as follows: 

• The on-road mobile emissions estimates for the maintenance plan were calculated with 

MOVES, which was not available at the time that the 2002 Periodic Emissions Inventory 

was prepared. On-road mobile emissions estimates for the 2002 Periodic Emissions 

Inventory were calculated using MOBILE6.2 emission factors. 

• Similarly, Stage II vehicle refueling emissions estimates (SCC 25-01-060-100) for the 

maintenance plan were calculated with MOVES and were included and reported in the 

on-road mobile category. Stage II emissions estimates for the 2002 Periodic Emissions 

Inventory were calculated using MOBILE6.2 emission factors, and they were reported in 

the area source category. Since this category is now calculated with MOVES and 

included under on-road mobile, the MOBILE6.2-based stage II refueling emissions 

estimates were removed from the area source inventory. This resulted in an adjustment 

to the 2002 maintenance plan area source inventory of -2,638 pounds per day of VOC 

when compared with the previously submitted 2002 Periodic Emissions Inventory. 
Page 4 of 5 

• In compiling the 2002 figures for the maintenance plan, it was discovered that emissions 

estimates for the industrial wood combustion category (SCC 21-02-008-000) should not 

have been calculated and reported under the area source category. All industrial wood 

combustion in 2002 would have occurred at permitted point source facilities, and 

making an area source estimate for this category caused double-counting. Therefore, 

the area source estimate for industrial wood combustion was removed. This resulted in 

a correction to the 2002 maintenance plan area source inventory of -25,357 and -880 

pounds per day of NOx and VOC respectively when compared with the previously 

submitted 2002 Periodic Emissions Inventory. 

This explanation has been added to Section 2.3 of the maintenance plan. 

10. Section 2.2 of the proposed maintenance plan for the 5-county attainment area mentions that 

growth factors from the Economic Growth and Analysis System (EGAS) were used to project point 

and area source emissions to 2012 and 2014. The final submittal should include the specific point 

and area source growth factors that were used to make these projections. 

Response: All of the supporting technical files for the projected 2012 and 2014 emissions 

inventories relevant to the Section 110(a)(1) maintenance plan are being provided to EPA on CDROM. These files include the EGAS factors that were used to do the projections. Because final, 

quality-assured emissions data for calendar year 2011 are not yet available, NHDES used 2010 

actual emissions data and the applicable growth factors to develop revised point source emissions 

estimates for the 2012 and 2014 inventories. Table 2-1 of the maintenance plan has been revised 

accordingly. 

Contingency Measures

11. On page 13 in Section 4, NH DES cites one reason to investigate an ozone season exceedance as 

“an anomaly in the ozone-season meteorology”. Since weather anomalies alone do not exempt NH 

DES from contingency measures, EPA recommends replacing this bullet with reference to 

“exceptional events,” as shown below: 

“2. If the design value is above the standard/or any ozone monitor, NHDES will investigate 

the cause and determine whether the exceedance is due to: 

• an increase in emissions from local, in-state sources; 

• an increase in emissions from upwind, out-of-state sources; or 

• an anomaly in the ozone season meteorology an exceptional event as defined in

40 CFR 50.1.” 

Response: The requested rewording has been made.

12. On page 13, EPA recommends that NH DES delete the word "significant" from the third step for 

the protocol, as shown below, since all factors contributing to ozone exceedances should be evaluated:

 “3. If an increase in in-state emissions is determined to be a significant contributing factor 

to the exceedance, NHDES will evaluate the projected in-state emissions for the next ozone 

season.” 

Response: The word “significant” has been removed.
Page 5 of 5 

13. On page 13, the 4th step of the protocol states: 

"The contingency measures(s) will be selected by the Governor or the Governor's designee 

within six months of the end of the ozone season for which contingency measures have been 

determined to be needed. New Hampshire will then initiate a course of action to implement 

enforceable control measures) to rectify the problem. New rulemaking, when required, can 

typically be adopted and implemented within a 12-month timeframe, assuming that no new 

legislation is required.” 

In the final submittal, NH DES should clarify the timeframe to implement contingency measures. 

Response: The end of the quoted paragraph has been revised to read as follows: “New rulemaking 

can typically be adopted and implemented within a 12-month timeframe. NHDES will update the 

maintenance plan as necessary and develop and implement required regulations as soon as 

practicable within the guidelines established in the New Hampshire Administrative Procedures Act, 

but no later than 18 months after selection of the appropriate measure.” 

14. The following sentence from page 18 of the section 110(a) maintenance plan should either be 

corrected, or clarified: 

“Note: New Hampshire previously prepared and submitted to EPA a 2008 periodic 

emissions inventory as required by the Clean Air Act.” 

It is not clear whether New Hampshire is referencing a periodic emissions inventory submittal and 

accompanying text write-up, such as the submittal New Hampshire made to EPA on June 7, 2007, 

of a 2002 periodic inventory, or whether this sentence is referring to New Hampshire's electronic 

data submittal to the EPA's national emissions inventory database of emission estimates for calendar 

year 2008. 

Response: New Hampshire was referencing the 2008 emissions inventory in a broad sense, as 

information that corroborates the observed downward trend in emissions. The broader 2008 

emissions inventory includes the electronic data submittal that New Hampshire made to EPA for 

inclusion in the 2008 National Emissions Inventory as well as the 2008 inventory SIP submittal that 

New Hampshire is making in conjunction with the 8-hour ozone redesignation request. The 

sentence in question has been revised accordingly.